January 21, 2020

Is Your Fleet Food Safe?

Written by Garret Weigel | FSMA, Supply Chain

Your fleet must be fully compliant with the FDA's Food Safety Modernization Act (FSMA) regulations in order to maintain good standing. This requires recurring self-assessment. As a food transporter, it’s important to answer questions about your fleet practice to help you stay prepared and in line with the new regulations. We've outlined five basic questions that you can start with to ensure that your fleet is food safe.

 

1) How are you managing temperature within your fleet?

This is one of the most important aspects of transporting perishable foods, especially if there is a high chance of foodborne illness. There are various ways to maintain temperature; however using the latest technology is often the best route to ensure that the temperature is not only maintained, but also monitored and controlled. Ideally, real-time temperature, as well as other parameters such as humidity and even a visual view of the product, should be monitored remotely from a dashboard of some type that allows you to see analytics of all the cargo being moved. Analytics like these allow any supply chain that's transporting temperature-sensitive food to monitor with a robust dashboard to see all the conditions as they exist at any point in time.

 

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2) Are you audit-ready?

FMSA calls for third-party audits to be performed on carriers and shippers that may be vulnerable to its regulations. This means you must not only be aware of all the requirements to stay in compliance, but you also must have data and information at the ready to show an auditor that you are in compliance. So, this begs the question: do you have a policy and procedure in place that will quickly and accurately provide auditors with necessary information to prove and substantiate your compliance? It's key to have a dedicated effort – perhaps a specific person assigned – that is responsible for ensuring that you are audit-ready and can fully pass an FSMA audit when the time comes.

 

checking paper logs

Rummaging through paperwork in case of an audit is time consuming and not guaranteed to contain the data you’re looking for.

 

3) Do you understand all your obligations under FSMA?

When the FDA invoked FSMA, they put out numerous regulations and requirements for different facets of food transportation. These facets include members of the supply chain and their various requirements. It's important to have some method of exploring, organizing, and knowing exactly what all the requirements are and, more importantly, what your obligations are from your specific function within the supply chain. It may not just be your organization that you need to be concerned about, but also your tier two and tier three suppliers that must maintain compliance. Ultimately, you're responsible for the food that's being moved and you must ensure that it's being transported safely in accordance with the requirements set forth in the law.

 

4) Do you understand all the written record-keeping requirements?

The specific record-keeping requirements depend on your role in the transport of food. If you're a shipper, there are written procedures that must be in place. If you're a carrier, there's another set of written procedures that must be established. If you're a cargo handler or operate a warehouse or a distribution facility for the food, other written procedures and records must be in place. Knowing all these requirements is important. But so is having some means of controlling them. It is vital to know, but more importantly understand, each of your obligations and responsibilities. Again, it would be wise to have one particular person assigned to ensuring that the written procedure requirements are not only understood but also implemented and compliant.

 

5) Are you developing and improving real-time alerts?

Current alerts can take many forms, but ordinarily utilize technology to send texts or to provide some sort of notification that there's a deviation from the specification or standard required for the food to be transported safely. It's your obligation to ensure that such alerts are in place and that they are working properly. Alerts must be rapid, current, and informative enough so that you can take action appropriately, any time or in any place that the food's being transported. If you receive notification that there is an air leak, or that a door was left open on a container, or that equipment failed causing temperature to degrade, it's your responsibility to have a proper alert in place that's going to not only notify you, but also give you ample time to respond. Therefore, it's important to invest in technology and continually find ways to upgrade and improve this technology to have proper vigilance of the condition of the food as it is being transported.

 

supply chain manager checking phone

Real-time alerts enable proactive management of temperature excursions, preventing problems before they occur.

 

Despite these questions being very basic, they provide you with a framework that allows you to ponder the different nuances that are involved in transporting food in today's global economy. Food is often transported through different modes of transportation, and it passes through different responsible parties. Ultimately, the responsibility will fall on you to deliver the food in safe condition that is sanitary and free of any health concerns. Consequently, these questions will allow you to better analyze and review your own control systems that are in place and know where, when, and how your controls are either working or not working. They act as a guideline to give you better practices to manage safe and quality food transportation.

 

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Topics: FSMA Supply Chain

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